HUD - PIH / REAC - TR/DBA Version 2.4 - May 2021 - Technical Reviews and Database Adjustments Guideline - Version 2.4 May 24, 2021
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Technical Reviews and Database
Adjustments Guideline
Version 2.4
May 24, 2021
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 1Technical Reviews and Database Adjustments
Multifamily property owners/agents (POAs) and Public Housing Agencies (PHAs) have
the option to appeal a physical inspection score for reasons such as a belief that the
inspection was not conducted in accordance with the Uniform Physical Condition
Standards (UPCS) inspection protocol, that certain inspection data may have been
recorded in error, or deficiencies are related to extraordinary events such as a natural
disaster, that, if corrected/adjusted will result in an improvement in the property's overall
score. There are two different processes available to appeal a physical inspection score:
technical reviews and database adjustments.
What is a Technical Review (TR)?
A technical review may be requested if, during the physical inspection, an objectively
verifiable and material error(s) occurred that, if corrected, would result in an
improvement in the property's overall score. Material errors are those that exhibit specific
characteristics and meet specific thresholds. The three types of material errors are:
Building Data Errors - The inspection includes the wrong building or a building
that is not owned by the property.
Unit Count Errors - The total number of units considered in scoring is incorrect
as reported at the time of the inspection.
Non-Existent Deficiency Errors - The inspection cites a deficiency that did not
exist at the time of the inspection.
What Does NOT Qualify for a Technical Review?
PIH-REAC will not consider the following for a technical review:
disagreements over the severity of a defect, such as deficiencies rated Level 3 that
the POA/PHA believe should be rated Level 1 or 2;
deficiencies that were repaired or corrected during or after the inspection;
deficiencies recorded with no associated point loss (for example, inoperable smoke
detectors) or deficiencies for survey purposes only (for example, FHEO);
deficiencies caused by residents.
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 2What are the Steps for Submitting a Technical Review?
A POA/PHA can initiate the technical review process by notifying PIH-REAC in writing
within the appropriate time-period and supplying objective and verifiable documentation
that a deficiency was recorded in error. Examples of objective and verifiable
documentation are identifiable, dated pictures or video evidence; signed and dated written
material from an objective source, such as a local fire marshal or building code official or
a licensed or registered architect or professional engineer with the authority to sign and
seal or ‘‘stamp’’ documents, thus taking the legal responsibility for them, or other similar
evidence that is specific to the inspectable area and item being challenged. The evidence
must be more than a disagreement with the inspector’s observations, or the inspector’s
finding regarding the severity of the deficiency.
As of October 31, 2007, appeals signed by the owner, his/her management agent and /or
lawyers retained by the owners are the only acceptable appeals that will be processed.
REAC is not required to review a request for appeal after the specified number of days
has expired so it is important to note the time-period available for appeal.
Public Housing: PHAs must submit a request for a technical review and must be
received at REAC within 30 days from the physical inspection report release date. This
change is effective for inspections released on or after March 25, 2011.The request must
include an email address of the request originator.
Multifamily: POAs must submit a request for a technical review and must be received at
REAC within 30 days from the physical inspection report release date. The request must
include an email address of the request originator.
The information and proper documentation for a technical review must be mailed to the
following address:
U.S Housing and Urban Development/PIH/REAC
Attn: Technical Assistance Center/TR/DBA
550 12th Street, S.W.
Suite 100
Washington, DC 20410
What Can Be Expected in Response to a request for a Technical Review?
If the PIH-REAC evaluation determines that an objectively verifiable and material
error(s) has been reasonably documented by the POA/PHA and, if corrected, would result
in a significant improvement in the property's overall score, the PIH-REAC will take one
or a combination of the following actions:
Schedule a new inspection;
Correct the physical inspection report;
Issue a corrected physical condition score; or
Issue a corrected Public Housing Assessment System (PHAS) score.
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 3An email will be sent to the originator of the request (a copy will be sent to the
Primary Contact listed in the inspection report) explaining what action, if any, has
occurred and why the technical review is accepted or denied. A technical review
that changes a physical inspection score may change the PHAS score. The PHAS
score is not considered final until all changes have been completed.
What is a Database Adjustment (DBA)?
A request for database adjustment initiates a review of the results of a physical
inspection. A database adjustment may be requested for circumstances affecting the
inspected property that are out of the ordinary, reflect an inconsistency with ownership,
or are allowed by city/county/state codes. Circumstances that may be addressed by a
database adjustment are as follows:
Local Conditions and Exceptions - Circumstances include inconsistencies
between local code requirements and the UPCS inspection protocol, such as
conditions permitted by local variance or license (e.g., child guards allowed on
sleeping room windows by local building codes) or preexisting physical features
that do not conform to or are inconsistent with PIH-REAC's physical condition
protocol.
Ownership Issues - Items that were captured and scored during the inspection
that are not owned or the responsibility of the PHA/POA. Examples include
sidewalks, roads, fences, retaining walls, and mailboxes owned and maintained by
adjoining properties or the city/county/state and resident-owned appliances that
are not maintained by the PHA/POA. The PHA/POA must have notified the
owner or proper authorities regarding the deficient item and any appliances
provided to the tenant must be noted in the lease agreement.
Adverse Conditions Beyond the Owner's Control - Deficiencies negatively
affecting the score were caused by circumstances beyond the PHA’s/POA’s
control, such as damage caused by a natural disaster; a third party, private or
public entity working near the property or caused damage to the property. The
responsibility to correct such conditions still belongs to the POA/PHA and must
show evidence of work completed or work physically in progress to complete
repair.
Modernization Work in Progress – Properties and developments undergoing
extensive modernization work in progress may qualify for a database adjustment
for observed deficiencies actively being worked on at the time of the inspection.
Routine and/or remedial maintenance before or during the inspection are not
appealable. All elements of the unit/area that are not physically undergoing
modernization at the time of the inspection (even if modernization is planned) will
be subject to PIH-REAC's physical inspection protocol without adjustment.
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 4What Does NOT Qualify for a Database Adjustment?
PIH-REAC will not consider the following for a database adjustment:
Requests submitted without appropriate documentation;
Deficiencies noted during the inspection that were corrected during or after the
inspection;
Circumstances addressed in the technical review process. Requests for technical
reviews must be submitted separately from requests for database adjustments.
What are the Steps for Submitting a Database Adjustment?
A POA/PHA can initiate the database adjustment process by notifying the correct office
in writing within the appropriate time-period and submitting proper documentation (i.e.,
signed letter from local/ building/ fire code official for code variance; etc) to support the
appeal. All requests for database adjustments can be made either prior to or after the
physical inspection
Public Housing: PHAs must send a request for a database adjustment and must be
received within 45 days from the physical inspection report release date to the local PIH
field office. The local PIH field office will then review the database adjustment request
and forward their recommendation to PIH/REAC. This change is effective for inspections
released on or after March 25, 2011. The request must include an email address of the
request originator.
Multifamily Housing: POAs must send a request for a database adjustment and must be
received within 45 days from the physical inspection report release date to the following
address. The request must include an email address of the request originator.
U.S Housing and Urban Development/PIH/REAC
Attn: Technical Assistance Center/TR/DBA
550 12th Street S.W.
Suite 100
Washington, DC 20410
What Can Be Expected in Response to a request for Database Adjustment?
If the PIH-REAC evaluation determines that the request is justified and, if corrected,
would result in a significant improvement in the property's overall score, the PIH-REAC
will take one or a combination of the following actions:
Schedule a new inspection;
Correct the physical inspection report;
Issue a corrected physical condition score; or
Issue a corrected Public Housing Assessment System (PHAS) score.
An email will be sent to the originator of the request (a copy will be sent to the Primary
Contact listed in the inspection report) explaining what action, if any, has occurred and
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 5why the database adjustment request is accepted or denied. A database adjustment
request that changes a physical inspection score may change the PHAS score. The PHAS
score is not considered final until all changes have been completed.
Examples of Appealed Items and Appropriate Documentation
Shown below are examples of appealed items and supporting documentation that is and
is not acceptable:
Examples of Objective and Verifiable Documentation not considered
observed deficiency Documentation objective and/or verifiable*
Letter from the PHA or the MF
A signed letter from a licensed Owner/Agent saying the wall is
(TR) Building
professional structural engineer sound and safe. Letter from a
Exterior -Foundations
with his/her seal stating that the general contractor/individual who
Cracks/Gaps
deficiency does not exist. is not licensed to give such
opinion.
A video or picture without a
date/time stamp. A letter from
the PHA/Property Owner/Agent
A dated picture or video showing
saying the vegetation is not
(TR) Site Grounds - the whole site that overgrown
overgrown. A time stamped
Overgrown, vegetation does not exist
video or picture showing
Penetrating Vegetation immediately prior to or on the
vegetation touching the building
inspection date
or growing over a walkway, etc. -
the inspector's judgment will
prevail.
(TR) Any inspectable
A pest control contract will not
area –
NA suffice to approve a TR. The
Infestation/Presence of
inspector’s judgment will prevail.
Roaches
A picture/video of the permanent
A letter from the PHA/POA that
art with a copy of the executed
says it allows children to mark on
contract between the PHA/POA
the walls. Although a TR can be
and the artist with a date prior to
approved for chalk hopscotch
the inspection or a newspaper
marks on a driveway/walkway;
article showing the artwork/mural
(TR) Site - Graffiti crayon and other permanent
done as a community project. A
markings on a wall, building
picture of temporary chalking
surface, or fence cannot be
such as hopscotch marks dated on
approved unless they are part of a
or within very few days after the
permanent piece of artwork/art
inspection clearly identifying the
mural.
area with the noted deficiency.
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 6A manufacturer’s guide that states
(TR) Common Area or seals/weather stripping was never A letter from the PHA/Property
Dwelling Unit Doors - installed and a picture which Owner/Agent saying there were
Deteriorated/Missing clearly identifies the inspected no seals on the door when it was
Seals (Entry Only) door that matches the purchased.
manufacturer’s guide.
(TR) Building
Signed letter from a licensed A letter from the PHA/POA
Systems - Leaking
professional mechanical engineer saying the leaking water was a
Central Water Supply
with his/her seal stating that the result of condensation rather than
(Domestic Water)
deficiency does not exist. a true leak.
An inspection report from a fire
sprinkler company or local code
official, dated on or immediately
(TR) Building A letter from the PHA/POA
after the inspection, that clearly
Systems - Missing saying they called the sprinkler
states the specific painted
Sprinkler (Sprinkler company and the vendor said it
components (frame, thermal
components painted was okay to paint the
linkage, cap, deflector, or
over) components.
escutcheon) do not affect the
effectiveness of the fire
suppression system.
An executed agreement dated
prior to the date of the inspection
and with appropriate contact
information, between the city and
the property owner stating the city
owns and is responsible for the
sidewalks or a letter from the city
(DBA) Site - Tripping Letter from the PHA or the MF
claiming ownership. Additionally,
Hazard (Sidewalk- POA saying the city owns the
there must be a letter from the
ownership) sidewalks.
PHA/POA dated prior to the
inspection reflecting a request for
the sidewalk to be repaired or a
letter from the city with
information regarding repair of
the sidewalk with appropriate
contact information.
(DBA) Common Area (1) an executed contract with a
Office - All copy of the scope of work,
inspectable items including change orders if
Letter from the PHA Mod
(undergoing applicable;
Coordinator or the MF Owner
modernization work- (2) a Notice to Proceed with start
saying the office is undergoing
in-progress) and completion dates; modernization.
(3) an affidavit from the
Effective Date contractor’s authorized
March 20, 2019 representative identifying:
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 7a. the modernization
work in progress that
was being done at the
time of the inspection;
b. the identifiable
location (e.g.
inspectable area, Bldg.
& unit number) of the
work physically in
progress;
c. the work it has
completed as of the
date of the affidavit;
d. the date on which the
work was completed;
and
e. if the work is not
completed as of the
date of the affidavit,
an explanation of why
the work is still in
progress and when it
will be completed; and
(4) photographic evidence
sufficient to show that the
observed deficiencies have
been corrected or are in the
process of being corrected.
Documents submitted from the
contractor(s) must be on the
contractor’s letterhead and
include the contractor’s licensing
and contact information.
Only the observed deficiencies
that were physically in the
process of being corrected by
modernization work in progress
at the time of inspection are
eligible for consideration.
Modernization work to be
performed under an executed
contract but was not physically in
progress at the time of the
inspection is not eligible for a
database adjustment.
Before processing a database
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 8adjustment, REAC may contact
the contractor for additional
information or visit the property
to verify the information
submitted in the appeal.
A letter from the local Fire
Marshall or licensed or registered
professional engineer with the
authority to sign and seal or
‘‘stamp’’ documents (thus taking
the legal responsibility for them,
or other similar evidence that is
specific to the inspectable area
and item being challenged. The
evidence must be more than a
disagreement with the inspector’s A letter from the PHA/Property
(DBA) Dwelling Unit observations, or the inspector’s Owner/Agent saying the local fire
Emergency Fire Exits finding regarding the severity of code allows window air
- Blocked/Unusable the deficiency) stating that conditioners. A letter from the
(Air Conditioner/Bars window air conditioners/bars in PHA/POA or tenant saying the
in the window) the window are allowed under the tenant requires the air
local fire code or that he/she or conditioner.
designee inspected the area in
question and the cited deficiency
does not pose any threat. Letter
should include the reasoning for
this decision such as the air
conditioner is not bolted in and
could be easily pushed through
the window to provide emergency
egress or the unit has a sprinkler
system.
A signed letter from an
owner/company with a contact Letter from the PHA or the MF
(DBA) Site -
number validating ownership of Owner/Agent saying another
Damaged/Leaning
the cited fence or an approved person/company owns the fence.
fence (ownership)
building permit/plan reflecting A photograph of the fence.
current ownership.
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 9A letter from tenant's doctor
stating the mechanical door closer
required adjustment to slow the
closing of the door, the door
needed to be removed, the lock
(DBA) Dwelling Unit needed to be removed, etc., to A letter from the PHA/POA or
– Damaged accommodate tenant’s medical tenant saying the elderly/disabled
Hardware/Locks/ necessity/disability. Letters must tenant needed the adjustment of
Missing Door be on appropriate letterhead with door hardware or the door/door
(database adjustment) contact information. The appeal hardware removed.
should include the work order
documenting request for
adjustment/removal of the
door/door hardware, dated prior
to the inspection.
A signed letter from a qualified
local code official on an official
letterhead noting the address of
(DBA) Missing
the property, the location of the
Breakers/Fuses
panel or item in question, a copy A letter from an electrician
(Electrical System –
of the photo taken by the REAC stating the repair is 'per the local
Building Systems)-
inspector at the time of code. '
Non-Industry
inspection and stating that the
Standard Repair
panel or item in question has
been inspected and meets local
code.
A signed letter from a qualified
local code official on an official
letterhead noting the address of
(TR) Missing
the property, the location of the
Breakers/Fuses
panel or item in question, a copy
(Electrical System – A letter from an electrician
of the photo taken by the REAC
Building Systems)- stating the repair is 'per specs. '
inspector at the time of
Non-Industry
inspection and stating that the
Standard Repair
panel or item in question has
been inspected and meets local
code.
Statements signed by residents or other personnel associated with the property are not
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 10considered objective third-party sources
Example of a technical review request
Deficiency: BE - Roofs - Ponding**
Documentation not considered objective and/or verifiable: Statement from the
POA/PHA that it rained the day before the inspection
Documentation considered objective and/or verifiable: Picture showing the roof is
flat and weather report showing measurable precipitation (1/10 inch or
more) during the previous 48 hours
Example of a database adjustment request
Adverse Conditions Beyond the Owner's Control
(1) Deficiency: Missing Pieces/Holes/Spalling (Walls)
Documentation not considered objective and/or verifiable: Statement from the
POA/PHA that a car ran through the wall 2 days before the inspection
Documentation considered objective and/or verifiable: Picture(s) and a police report
HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 11Pre-database adjustment When an appeal with corresponding proper documentation wherein the deficiency captured conforms to the local code or pertains to ownership matters, the property ID is added to our “pre-database” list. This means when the subsequent inspection noted deficiency that received points was granted on a previous appeal, that specific deficiency will be deleted prior to release of the new inspection report View the Applicable Federal Register Notices/Regulations PIH-REAC has provided the database adjustment guidelines in the Federal Register notices for 24 CFR Part 200.857 and 24 CFR Part 902.24. PIH-REAC has provided technical review guidelines in the Federal Register at 24 CFR Part 200.857 and 24 CFR Part 902.68. HUD – PIH / REAC – TR/DBA Version 2.4 – May 2021 Page 12
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